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    <title>1958 (4) TMI 123 - ORISSA HIGH COURT</title>
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    <description>Whether sums received under an Annadan Patra qualified as income applicable solely for public religious purposes under section 4(3) of the Income-tax Act was decided by applying the public v private trust test: the trust benefits were limited to the Panda and a definable class of jajman pilgrims, indicating a private religious trust. The court rejected expanded registry-based beneficiary claims, held the assessee bore the burden of proof and had not discharged it, and concluded the income was not exempt under section 4(3), favouring the Revenue.</description>
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      <link>https://www.taxtmi.com/caselaws?id=276802</link>
      <description>Whether sums received under an Annadan Patra qualified as income applicable solely for public religious purposes under section 4(3) of the Income-tax Act was decided by applying the public v private trust test: the trust benefits were limited to the Panda and a definable class of jajman pilgrims, indicating a private religious trust. The court rejected expanded registry-based beneficiary claims, held the assessee bore the burden of proof and had not discharged it, and concluded the income was not exempt under section 4(3), favouring the Revenue.</description>
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